I am a defendant in a fast track case.
I have the other parties documents I requested copies of from their disclosure by list.
There are other docs I know of the existence of and want the other party to disclose them as I think they have left them out because they will hurt their case.
I have written to them requesting these be disclosed but have not heard back or received supplemental disclosure of these docs. I don't expect to hear back as they refuse to communicate with me regarding this litigation.
I am planning to apply for a Specific Disclosure order and cannot find much guidance online on how to go about this.
I want them to disclose specific documents, rather than to do an additional search as I think these should have been found and disclosed within the search they already carried out.
There are 11 docs in total I want them to disclose.
Some of the docs are mentioned by them in emails they disclosed, some are police records they can get through a subject access request, they have disclosed the Crime Ref numbers of these incidents and referred to them in letters they disclosed.
My questions are:
1. What do I put in the draft order?
2. What do I put in my supporting evidence/information to support the application?
3. How do I refer to the places that bought these documents existence to light?